Privacy

Who are we?

“We” are William Russell Limited, and we are a data controller of the personal information we process. Our address is: William Russell House, The Square, Lightwater, Surrey, GU18 5SS, United Kingdom.

What information do we collect?

We collect information you give us as part of your application, and in correspondence with us by phone, email, post or other means of communication. This information may include personal information, such as:

• Name
• Address
• Telephone number
• Email address
• Date of Birth
• Bank details
• Occupation
• Nationality
• Residency
• Information about you gained from analysis or profiling
• Income

We will also collect sensitive personal information, such as details of your physical and mental health in order to provide our products and services where we have a contractual basis to do so.

What if you do not provide personal data?

Failing to provide the personal information we require in order to provide you a quote, underwrite and administer your plan, or to process your claims, could result in your claims being rejected or not being fully paid, your plan being cancelled, or in us being unable to provide you with a quote or offer cover.

Who do we collect information from?

In addition to the information you provide us, we may receive information about you from third parties, such as:

• Your broker or representative (if you have appointed one)
• The main policy holder of your plan
• Your employer
• Your partner, spouse
• Your parent or legal guardian
• The medical facility or those involved in your treatment
• Third parties who provide services to us, including our:
  • Payment service provider
  • Emergency assistance providers
  • Other insurance companies in relation to fraud prevention services
  • Social media channels where you have provided consent to relevant channel to share information

How we use your personal information

We will only collect information that is necessary to provide you with the services we offer and where we have a legal basis for which to process your information.

Where we have a contractual basis in providing you with our products or services, such as:

• Providing you with a quote
• Underwriting and administering your plan
• Communicating with you about your quote and/or plan
• Processing claims

In the event of a claim, we may have to give some information to those involved in your treatment or care, or to your representative (if you have chosen one). This will be done confidentially. Unless specifically instructed, correspondence about all claims (including those made by dependants) will be addressed to the plan holder. An insured dependant over the age of 16 has the right to confidentiality in relation to their claims and information. For them to exercise this right, they should contact member services. If you have another insurance plan that covers the same costs that you are claiming from us, then we may also disclose your relevant personal information to that other insurer so we can ensure that we only pay our proportion of the costs.

Where we have a legitimate interest in processing your information, such as:

• Research or statistical analysis to help us improve our services
• Informing you of additional products or services available under your plan that you may be eligible for
• Recording of telephone calls for the purposes of monitoring quality of our service and for training purposes
• Our business processes, such as auditing, business planning, and accounting
• Sharing your information with other insurers with the view to identifying and preventing fraud, and to seek contribution towards the cost of a claim

Where we have legal and regulatory obligations, such as:

• to comply with our legal and regulatory obligations
• Sharing your information with the authorities where we are required to by law

Where you have provided your consent for us to process your information, such as:

• Marketing to you
• Keeping you informed about our products and services
• Sharing insights and information about expat lifestyles
• When you first visit our website we ask for your consent, to the use of cookies that enable us to track user journeys and allow us to keep on improving the user website experience. For further information on our Cookie policy please click here

Profiling and automated decision making

We do not make decisions relating to cover available under our plans based solely on automated decision-making.

Who we may share information with

We may disclose your personal information to our business partners for the purposes listed above, these third parties include:

• Our providers of payment services for processing payments
• Organisations (such as regulatory authorities) where we have a duty to disclose or share your personal information to comply with legal obligations
• Other members of our group to enable us to provide services to each other that assist with the administration of insurance policies and claims
• The provider of our insurance administration systems and providers of technical support services for those systems
• Providers of research and analysis services to help us improve our products and services
• Providers of marketing services where we have your consent to market to you
• The insurers or reinsurers of your plan on whose behalf we underwrite our plans and handle claims and any of their group companies that can assist us with the administration of your policy and/or claims
• Our emergency Assistance Service providers in order they can provide an out of hours service for our members
• Your insurance broker or representative (if you have appointed one) in providing quote and policy documentation to share with you
• Other parties (such as other insurance companies, claims assessors and investigators) with a view to assisting us to verify coverage, preventing fraudulent or improper claims, and to seek contribution from other insurers towards the cost of a claim.
• Your employer in relation to a quote or cover provided under a corporate scheme
• Your partner, spouse, parent or legal guardian in providing our products or services described above
• The medical facility or those involved in your treatment
• Cost agents and other third parties who may assist us by managing relations with your medical service providers and by providing payment guarantees for your treatment
• The main policyholder of your plan

How we keep, store, and dispose of your personal information

We hold your information in various forms, including electronic databases, computerised files, and paper files.

We operate an information security management system and have a framework of policies and procedures in place to ensure personal information is processed securely.

Information may be held for a period after your plan ends. This will generally be for a period of 6 years from when a plan lapses and any outstanding claims have been settled, in order to comply with legal obligations and to defend a claim that can brought against us during this time.

If you have received a quote from us your information will usually be deleted after the 30-day validity period, if the quote has not been taken up as the quote will no longer be valid.

In certain circumstances it may not be possible to determine the period for which personal information will be held, this can include where we hold personal information for the purpose of detecting and preventing fraud, or as we are required to in accordance with legal and regulatory requirements for retaining records.

When we dispose of your information, we will do so securely. We may continue to keep non-personally identifiable information for the purposes of research and statistical analysis to improve the services we offer.

Where we transfer your personal information

The information we collect from you may be transferred to and stored at a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside of the EEA who work for us or for one of our suppliers.

We will take all steps necessary to ensure that personal information is treated securely and in accordance with this data protection notice. This can include having agreements with suppliers that include approved contractual clauses, requiring suppliers sign up to an approved code of conduct or are certified by an approved certification mechanism.

How we use cookies to improve your website experience

We use cookies and similar technologies on this website. Cookies are text files containing small amounts of information, which your computer or mobile device downloads when you visit a website. When you return to websites, or visit websites that use the same cookies, they recognise these cookies and therefore your browsing device.

Like most financial services providers, we use cookies to do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences and generally improving your browsing experience. They can also help ensure that ads you see online are more relevant to you and your interests. We also use similar technologies such as pixel tags and JavaScript to undertake these tasks.

If you visit our website we deploy these technologies to provide an online service more suited to the device you connect from, as well as to prevent and detect fraud, keeping you secure. When you visit our website from any device (mobile, tablet or computer), we collect information about your use of this site, such as information about the device or browser you use to access the site (including device type, operating system, screen resolution etc.), the way you interact with this site, and the IP address your device connects from.

We use cookies to:

• Ensure your security and privacy when in our secure sites
• Temporarily store input information in our quote tools
• Provide you with ads that are more relevant to you and your interests, and improve our targeting and enhance your journey through our sites and partner sites
• Improve our understanding of how you navigate through our sites so we can identify improvements, and
• Evaluate our sites’ advertising and promotional effectiveness (we own the anonymous data collected and don’t share it with anyone)

We use both our own (first-party) and partner companies’ (third-party) cookies to support these activities

• Cookies generated on our website are passed through to third party services used to support our website functionality.
• Our use of cookies can lead to personally identifiable information being collected and stored within the UK, e.g., if you use our quote tool a record is created in our third-party tools and Dynamics (our member records management system.)

Setting your cookie preferences

You can control how cookies are placed on your device within your own browser.

What happens to cookies that have been downloaded in the past?

You can delete existing cookies from your browser. Historical information collected from any cookies will be anonymised and used by William Russell to review or compare our websites and advertising performance.

More information about cookies

Internet Advertising Bureau:

• https://www.allaboutcookies.org^

International Chamber of Commerce United Kingdom:

• Guide to online advertising and privacy^
• CC UK cookie guide PDF†

Your rights over how your data is processed

You have, the following rights with regards to how your personal information is processed. Please note some of these rights do not apply in all circumstances.

• The right to be informed about how we collect and use your personal information.
• The right to request access to the information we hold about you.
• The right to rectification if you believe any information we hold about you is inaccurate or incomplete.
• The right to erasure, also referred to as the right to be forgotten which applies in certain circumstances, whereby you can request us to delete any information we hold you that we have no valid reason to continue holding or processing the information.
• The right to restrict processing applies in certain circumstances and allows you to request us to suspend processing your information in certain circumstances.
• The right to data portability enables you to request a copy of electronic personal information you have provided us, or for it to be transferred to another data controller (e.g., provider) in certain formats where practicable.
• The right to object to us processing your personal information in certain circumstances. You also have the right to object where we are processing your personal information for marketing purposes.

To exercise any of these rights, please contact:

Data Protection Officer

William Russell Ltd.

William Russell House

The Square, Lightwater

Surrey, GU18 5SS, UK

Email: contact@william-russell.com

If you believe we are not processing your personal data in accordance with the law, please contact our data Protection Officer in the first instance who will investigate and attempt to resolve your complaint, alternatively you can complain to the UK Information Commissioner’s Office, the ICO, via this link: https://ico.org.uk/concerns/

Marketing

You have the right to ask us not to process your information for marketing purposes. We will always inform you (before collecting your information) if we intend to use your information for such purposes and seek your consent to do so. You can withdraw your consent for us to use your information in this way at any time.

Changes to our privacy policy

There are occasions where we will, from time to time, update our privacy information, such as when there is a change in the law, or a change in the way we intend to use personal information. It is worth checking this policy for changes; however, we will contact you to inform you of any changes to this policy and what the changes are and why we are making them.